On December 29, 2014, Uruguayan Congress ratified the Tax Information Exchange Agreement entered into between Uruguay and Brazil (“the TIEA”).
The TIEA is patterned after the OECD Model. The Contracting Parties undertake to cooperate with each other through the exchange of any information which might be foreseeably relevant for tax purposes. The information to be exchanged under the TIEA is comprehensive (any data, statements or documents). The Requested Party is required to conduct all administrative or judicial proceedings which may allow the Requested Party to obtain and deliver the requested information.
Fishing expeditions may be denied by the Requested Party.
Inspections by the Tax Office of either country in the other country are allowed, with the prior approval of the Requested Party and in the manner to be previously coordinated with the Requested Party.
The TIEA will enter into force 30 days counted as from the exchange of notices (between the Contracting Parties) confirming that the TIEA has been enacted in accordance with respective local rules.
Since the initial TIEAs entered into in effect in Uruguay in 2011-2012, Uruguay has received an average of approximately ten (10) information requests per year. Most of them come from Argentina and involve corporate taxes emerging from international trading transactions.